California seeks input for 750-GWP limit on AC refrigerants

CARB meeting addresses definition of ‘new equipment’ and whether chillers should be included in regulations.

In a technical working group meeting last week, the California Air Resources Board (CARB) sought input from industry stakeholders on a proposal to cap the GWP of refrigerants in stationary air conditioning equipment to 750 starting January 1, 2023.

Among the topics discussed at the March 6 meeting were whether CARB should set a GWP limit for chillers; how “new equipment” should be defined; and what mechanisms best support enforcement.

In 2017, California determined that commercial air conditioning accounts for 18% of HFC emissions while residential air conditioning generates 16%.

California has already taken a number of steps toward regulating the use of high-GWP HFC refrigerants in order to meet its mandate of cutting HFCs by 40% below 2013 levels by 2030. For example, In March 2017, CARB approved a SLCP (Short-Lived Climate Pollutant) Strategy), which includes cutting HFCs.

Last year, the state passed legislation called the California Cooling Act that adopted the U.S. Environmental Protection Agency’s SNAP Rules 20 and 21 by reference, with the exception of motor vehicle air-conditioning. SNAP rules 20 and 21 include bans on high-GWP HFCs in a variety of applications by certain dates.

The SLCP Strategy allows CARB to set more stringent regulations than the SNAP bans adopted in the California Cooling Act, including a 750-GWP cap on refrigerants (two or more lbs) in stationary ACs, and a 150-GWP cap on refrigerants (50 or more lbs) in new stationary refrigeration equipment beginning in 2022.

ACs covered by the 750-GWP cap would include room and portable units, packaged terminal ACs and heat pumps, commercial ACs and heat pumps, computer room ACs, among other AC types.

The 750-GWP cap for ACs was endorsed in a letter last year to CARB from an industry coalition and the National Resources Defense Council. Manufacturer Emerson (not in the letter) expects CARB to announce a final regulation on ACs by the end of 2019.

What about chillers?

Though used in commercial air conditioning, chillers were not included In CARB’s original AC plans, though SNAP rule 21 includes bans on high-GWP refrigerants (such as R410A and R134a) in a variety of new chiller types by 2024. At the March 6 meeting, CARB raised whether to set a GWP limit, such as 750, for particular chiller types by 2024 (as opposed to 2023 for the rest of AC applications).

“We want to set a GWP limit for chillers for 2024,” said Kathryn Kynett, CARB’s air pollution specialist during the meeting. “It is hard to predict what may happen with HFCs in future [EPA] approvals. That is why we’re asking what type of chillers may not be able to [achieve] that 750-GWP limit.”

CARB estimated that equipment under the new regulations would cost up to 15% more to purchase, ranging from 0-1% for room/portable equipment to 5-15% for commercial ACs and heat pumps. Installation costs were estimated to go up 5-10%.

The CARB meeting also addressed whether “new AC equipment” should be defined as only new construction or also modified systems – such as when major components are replaced or added, or when a certain cost threshold is passed.

Also considered was the type of mechanism that would best support enforcement, including labelling, disclosure, recordkeeping and reporting.